20170723 Ver 1_Final B2500 mit plan_20170607

Final Wetland Mitigation Plan
NC 12 Replacement of Herbert C. Bonner
Bridge
(Bridge No. 11) over Oregon Inlet
Federal-Aid No. BRS-2358(I S)
NCDOT Project Definition: 32635
TIP PYoject No. B-2500
Dare County, North Carolina
Prepared by
United States National Park Service
North Carolina Department of Transportation
January 30, 2013
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TABLE OF CONTENTS
BASELINEINFORMATION ...................................................................................................................... 3
MITIGATION GOALS AND OBJECTIVES .............................................................................................. 4
MITIGATION OBJECTIVES .................................................................................................................. 5
AFFECTED WETLANDS AND MITIGATION ......................................................................................... 8
INTENDED COMPENSATION CONTRIBUTION ............................................................................... 8
ONSITEMITIGATION ........................................................................................................................... 9
EFFECTS OF PHRAGMITES INVASION OF COASTAL MARSHES ..............................................11
TREATMENTOPTIONS ..........................................................................................................................13
PROPOSED MITIGATION .......................................................................................................................14
WORKPLAN .........................................................................................................................................14
ADAPTNE MANAGEMENT ...............................................................................................................16
SITE PROTECTION AND MAINTENANCE ..........................................................................................21
FINANCIAL ASSURANCES .................................................................................................................... 21
PROJECT COMMITMENTS .....................................................................................................................21
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BASELINE INFORMATION
This Wetland Mitigation Plan details the proposed mitigation to be performed by the North
Carolina Department of Transportation (NCDOT) for wetland impacts associated with the
NC 12 Replacement of the Herbert C. Bonner Bridge over Oregon Inlet. Impacts to
Section 404 jurisdictional wetlands on Federally owned lands managed by the National
Park Service (NPS) and by the United States Fish and Wildlife Service (USFWS), within
the Cape Hatteras National Seashore (the Seashore), will occur during Phase I of the bridge
replacement. The proposed mitigation will be used to offset impacts for Phase I and for
future phases as appropriate. Section 404 jurisdictional wetland impacts associated with
Phase I of the Selected Alternative will be approximately 0.50 acres, of which 0.02 acres
are considered CAMA jurisdictional wetlands.
The NPS worked with NCDOT to identify potential compensatory mitigation sites for the
anticipated impacts to Section 404 jurisdictional wetlands. Several mitigation options were
explored and prioritized. These options are discussed in detail in the Final Environmental
Impact Statement (FEIS) dated September 17, 2008.
The NPS identified restoration of high-quality wetland communities designated as
Significant Natural Heritage Areas (SNHAs) within the NPS property as the highest
priority mitigation option. Many sites with high-quality or rare natural communities, rare
species, and special animal habitats have been identiiied by the NPS and North Carolina
Heritage Program (NCNHP) as being important for conservation of the State's biodiversity.
The ecological significance of these areas has been documented through a 1987 Registry
agreement, as amended, for the protection and management of Significant Natural Heritage
Areas (SNHAs).
The NPS has identified the Bodie Island Lighthouse Pond SNHA as one such area (vicinity
of 35°49'7.07"N, 75°33'48.60"W). NCDOT field surveys and mapping efforts estimated
that approximately 50 acres of formerly Spartina-dominated marsh habitat has been
displaced by the invasion of the exotic plant Phragmites in an area surrounding the Bodie

Island Lighthouse. This Wetland Mitigation Plan identifies the proposed work plan and
performance measures to guide the restoration of the former marsh habitat through exotic
plant control measures in this area of high management priority within the Seashore.
MITIGATION GOALS AND OBJECTIVES
The goal of this proposed mitigation plan is to compensate for unavoidable wetland
impacts by developing a single proposal that (a) meets the compensation requirements of
both the Executive Order 11990: Protection of Wetlands and the USACE Section 404
permit procedures (33 CFR 320-330); and (b) meets the NPS goal of "no net loss of
wetlands" on NPS property. As explained in E.O. 11990, a Wetland Statement of Findings
(SOF) must be prepared if an NPS action has the potential to have adverse impacts on
wetlands unless the action is "excepted". A Wetland SOF is being prepared under separate
cover for the B-2500 bridge replacement project. This mitigation plan is excepted from the
requirement of a Wetland SOF under Section 4.2.1 (h): Actions designed to restore
degraded (or completely lost) wetland, stream, riparian, or other aquatic habitats or
ecological processes.
Compensatory mitigation means the restoration (re-establishment or rehabilitation),
establishment (creation), enhancement, and/or in certain circumstances preservation of aquatic
resources for the purposes of offsetting unavoidable adverse impacts which remain after all
appropriate and practicable avoidance and minimization has been achieved. Restoration should
generally be the first option considered because the likelihood of success is greater and the
impacts to potentially ecologically important uplands are reduced compared to establishment,
and the potential gains in terms of aquatic resource functions are greater, compared to
enhancement and preservation.
Mitigation options are defined below according to COMPENSATORY MITIGATION
FOR LOSSES OF AQUATIC RESOURCES, 33 CFR PART 332:
1. Restoration means the manipulation of the physical, chemical, or biological
characteristics of a site with the goal of returning natural/historic functions to a former or
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degraded aquatic resource. For the purpose of tracking net gains in aquatic resource area,
restoration is divided into two categories: re-establishment and rehabilitation.
a. Re-establishment means the manipulation of the physical, chemical, or biological
characteristics of a site with the goal of returning natural/historic functions to a
fortner aquatic resource. Re-establishment results in rebuilding a former aquatic
resource and results in a gain in aquatic resource area and functions.
b. Rehabilitation means the manipulation of the physical, chemical, or biological
characteristics of a site with the goal of repairing natural/historic functions to a
degraded aquatic resource. Rehabilitation results in a gain in aquatic resource
function, but does not result in a gain in aquatic resource area.
2. Establishment (creation) means the manipulation of the physical, chemical, or biological
characteristics present to develop an aquatic resource that did not previously exist at an
upland site. Establishment results in a gain in aquatic resource area and functions.
3. Enhancement means the manipulation of the physical, chemical, or biological
characteristics of an aquatic resource to heighten, intensify, or improve a speciiic aquatic
resource function(s). Enhancement results in the gain of selected aquatic resource
function(s), but may also lead to a decline in other aquatic resource function(s).
Enhancement does not result in a gain in aquatic resource area.
4. Preservation means the removal of a threat to, or preventing the decline of, aquatic
resources by an action in or near those aquatic resources. This term includes activities
commonly associated with the protection and maintenance of aquatic resources through
the implementation of appropriate legal and physical mechanisms. Preservation does not
result in a gain of aquatic resource area or functions.
MITIGATION OBIECTIVES
The proposed on-site mitigation, defined as restoration above, provides for the
rehabilitation of the integrity of natural resources, native vegetation mosaic, and habitat
values at the Bodie Island Lighthouse Pond. In a December 2010 meeting with NCDOT,
the NPS identified this site as a high management priority within the Seashore.

Examples of high management priority areas are areas that have been jointly identi�ed by
NPS and the North Carolina Natural Heritage Program (NCNHP) and are Registered
Significant Natural Heritage Areas (SNHAs). Registration of SNHAs means that the NPS
and NCNHP have signed a Registry agreement that documents their joint interest and
commitment to protect the integrity of natural resources within a particular area. The 1987
Registry agreement states that the NPS will:
....refrain from making or permitting changes that negatively affect the natural
values for which [these areas were] registered....Specifically, the National Park
Service agrees to manage and maintain the designated natural areas for the
perpetuation and protection of their primary biological resources. In some cases,
manipulation—by burning, mowing, cutting, control of exotic species, managed
water levels, or placement of dredged materials—may be appropriate to control
natural vegetational succession and maintain habitats for rare or special-interest
species...A monitoring program will be maintained for endangered and threatened
species of animals and plants.
Each SNHA profile includes specific management action recommendations. The following
management goals in this plan are based on those identified in national invasive species
guidance, including the National Invasive Species Management Plan (National Invasive
Species Council, 2008). Each goal has a set of related management objectives, which are
statements of purpose that describe what must be accomplished for the plan to be
considered a success in the Seashore. Adaptive management, an integral part of this plan,
is a process that allows for decision making in spite of uncertainty, with an aim to reduce
uncertainty over time via system monitoring. This process allows resource objectives to be
met while information is gathered and lessons are learned, in hopes of continually
improving future management.
Independent of the specific project location, the following goals and management
objectives are applicable to exotic plant control efforts within the Seashore:
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Goal 1: Inventory — Initiate a comprehensive and systematic exotic plant inventory
to establish a baseline from which to measure progress.
Management Objectives:
o Document the abundance and distribution of exotic plants in the target
.�i:�;�y
o Provide a foundation for prioritizing threats and for carrying out
management planning efforts
o Provide a foundation for the development of short- and long-term
programmatic plans
Goal 2: Treatment — Treat exotic plant populations that pose the greatest threat to
park resources.
Management Objectives:
o Use the most effective and appropriate tool, or combination of tools, to
eradicate or reduce the impact of exotic plants
o Reduce the impact of exotic plants on sites of cultural, scenic, and high
ecological value, including habitat for special status species
o Restore ecosystems and key ecological processes that have been affected
by invasive species to meet desired future conditions
o Integrate ecological restoration practices in exotic plant control
treatments to guard against reinfestation
o Minimize secondary impacts from control efforts
o Protect human health and safety of persons potentially affected by the
exotic plant control treatments
Goa13: Monitoring — Ensure that the exotic plant control program is regularly
monitored and improved, environmentally safe, and supported by science and
research.
Management Objectives:
o Monitor and evaluate the overall program effectiveness to inform
management regarding whether the program is of sufficient scope to
meet program goals
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o Monitor and evaluate the effectiveness of control techniques by species
and adapt as necessary, based on results
o Monitor effects on native plant communities, based on results, adapt
control techniques
o Identify vectors of spread to determine ways of preventing new species
and populations from becoming established in targeted areas
o Promote research in the park upon which to base future management
decisions
Goa14: Educate, Outreach, and Research — Educate, inform, consult, and
collaborate with stakeholders (e.g., NPS and other government agencies,
organizations, concessioners, visitors, partners, private property owners, and
gateway communities) to share information and address exotic plant issues.
Managenzent Objectives:
o Continue developing partnerships to encourage participation in the
management of exotic plants throughout the Outer Banks region
o Expand collaborative efforts among park neighbors, park partners,
gateway communities, and the public to share methods of preventing and
controlling the spread of exotic plants
o Ensure that interested parties are well-informed about the timing and
locations of upcoming exotic plant control treatments
o Educate and inform park visitors on exotic plants
o Provide stewardship opportunities for the public
o Continue to support and develop exotic plant research
AFFECTED WETLANDS AND MITIGATION
INTENDED COMPENSATION CONTRIBUTION
The proposed construction of B-2500 will permanently impact 0.50 acre of jurisdictional
wetlands, which includes 0.01 acre CAMA jurisdictional wetlands.
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Individual impact sites and acres are summarized in the wetland impact sheet included in the
permit application. Specific community descriptions and wetland types are described in
detail in the Final Environmental Impact Statement dated September 2008.
ONSITE MITIGATION
To date, the NPS has identified the rehabilitation of approximately 50 acres of wetland
within the Bodie Island Lighthouse Pond SNHA as the highest priority site for the
proposed on-site mitigation for wetland impacts. The NPS and NCNHP identified control
of exotic plant species is essential to prevent the degradation or loss of function of this
SNHA.
Bodie Island Ligthouse Pond SNHA (Site Id #1134�
The Bodie Island Lighthouse Pond is located on the Oregon Inlet 7.5 USGS topographic
quad map, approximately 3 miles north of Oregon Inlet. It is the largest pond in the
Seashore, measuring nearly one mile long and 0.4 mile wide. This fresh to slightly
brackish pond is likely not a natural body of water. It was probably created by a waterfowl
hunt club by placing a dam on a small outlet stream to the Pamlico Sound. However, the
history of the pond is poorly known, and it predates the designation of the C ape Hatteras
National Seashore.
Today, the Lighthouse Pond is primarily used for nature study. Large numbers of
birdwatchers and sightseers visit the pond each year, accessing the Pond area on a recently
upgraded (now handicap-accessible) wildlife viewing platform. Hunting and fishing are
prohibited.
The site was described by the NCNHP as having significance due to its outstanding
collection of water birds, with several rare plant and animal species. Historically, the pond
was bordered by a diverse, though somewhat narrow, border of fresh-brackish marsh.
Several rare plants occurred in the marsh. The Lighthouse Pond is habitat for very large
numbers of waterbirds, making it one of the best bird watching sites in North Carolina
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(Buchanan 2009). For most of the year, thousands of waterbirds forage in the mud and
shallow water at the pond. Several species of waterfowl nest in the vegetation at the edge
of the pond, including black duck, gadwall, and blue-winged teal. During the warmer
months a large variety of shorebirds, herons, egrets, and ibises forage at the pond. Several
uncommon shorebird species occur annually, including Hudsonian godwit and Wilson's
phalarope. From early autumn into spring, the pond is often covered with waterfowl
including tundra swans, Canada geese, and snow geese. Peregrine falcons pass through the
area in fall migration, and one or two individuals are often present in the vicinity of the
pond in fall or winter.
The following lists the special status species of plants and animals known to occur in the
vicinity of the pond:
• Black-necked stilt (Himantopus mexicanus), State Signiiicantly Rare
• Peregrine falcon (Falco peregrinus), State Endangered
• Black rail (Laterallus jamaicensis), State Species of Concern
• Saltmarsh spikerush (Eleocharis halophila), State Threatened
• Beaked spikerush (Eleocharis rostellata), State Threatened
• Olney's three-square (Schoenoplectus americanus), State Watch List
The 1987 Registry agreement includes specific management and protection
recommendations for the Bodie Island Lighthouse Pond SNHA. The site will continue to
be a visitor destination within the Seashore, for birdwatchers and lighthouse tourists alike.
However, the NPS is presently neither managing the water level for the benefit of the bird
populations nor is the NPS presently monitoring or managing infestations of exotic plant
species, with a specific emphasis on Phragmites australis.
The European genotype of the common reed (P. australis) occurs in large bands around the
edge of the pond; this is an exotic species which is now abundant in habitats once occupied
by the genotype native to the United States. Population decline and local extinctions of the
native genotypes may be a result of competitive displacement by the exotic genotype
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and/or anthropogenic disturbance. Approximately 900 acres of marsh are infested by the
exotic P. australis throughout the entire Seashore. In 2008, the NPS originally estimated
and mapped approximately 35 acres of marsh infested by the exotic P. australis within the
Bodie Island Lighthouse Pond SNHA. In 2011, NCDOT in coordination with NPS mapped
51.73 acres of phragmites within the marsh at Bodie Island Lighthouse pond.
EFFECTS OF PHRAGMITES INVASION OF COASTAL MARSHES
Phragmites australis is a tall perennial grass which can attain heights of up to 4.5 m
(USACE 2005), significantly greater than that of native marsh species, such as Spartina
alterniflora, Spartina patens, Juncus roemarianus, and Typha latifolia. Although it is a
proli�c seed producer, Phragmites most often spreads locally through vigorous growth of
rhizomes and stolons, which can grow up to 2 m per year (Batterson and Hall 1984).
Phragmites can eventually sustain stem densities of up to 300 culms per square meter
through development of a dense root mat (Hara et al. 1993). In addition to vigorous
biomass growth, Phragmites is also reported to release the allelopathic chemical gallic acid
into the soil, which inhibits the establishment and growth of other marsh species (Rudrappa
et al. 2007). As a result of these physiological characteristics, Phragmites, once
established, frequently develops dense, monospecific colonies over extensive areas and can
exclude shorter native marsh species (USACE 2005). The Virginia Department of
Conservation and Recreation (2009) reported that aggressive Phragmites colonies
threatened the habitat of 29 rare plant species in Virginia.
The effect of Phragmites invasion on communities of associated wildlife has been most
pronounced with respect to birds. While the observed effect on populations of native fish,
benthic infauna, aquatic invertebrates, and decapod crustaceans has been variable (Posey et
al. 2003, Hanson et al. 2002, Able and Hagan 2000, Fell et al. 1998), the shift in habitat
from native low marsh vegetation to monotypic stands of Phragmites has demonstrated a
more consistent effect on bird populations. In a study of marsh birds in Connecticut, it was
demonstrated that there were fewer species present in Phragmites-dominated stands than in
native short-grass marshes, particularly among rare bird species (Benoit and Askins 1999).
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The authors concluded that the dense, montypic stands of Phragmites reduce the structural
habitat heterogeneity and plant diversity needed by many species. In addition, the height
and density of the thick Phragmites stems may physically exclude waterfowl and wading
birds from the marsh interior, or substantially reduce hunting efficiency, rendering these
sites unproductive. Similarly, Bontje (1987) found increased bird richness in restored
cordgrass marshes compared with reference Phragmites, and Paxton (2007) reported that
avian marsh species in Virginia rarely utilized stands of Phragmites. Phragmites has been
reported to negatively affect the habitat of 22 rare animal species including 13 birds in the
state of Virginia (VDCR 2009).
Some researchers have suggested that changes in vegetation growth form and structure
between native marsh grasses and invasive Phragmites may affect soil and hydrology
characteristics of wetland sites. Phragmites colonies typically have fewer but signiiicantly
larger stems than native species, which may affect water flow through the marsh, sediment
deposition rates and processes, detrital production and accumulation rates, sediment
organic content, and nutrient cycling (Meyerson et al. 2000, Talley and Levin 2001, Rooth
and Stevenson 2000, Windham 2001, Leonard et al. 2002). Windham and Lathrop (1999)
stated that Phragmites stands may increase detritus accumulation over time, and thus, may
elevate the substrate surface and smooth surface microtopography. Such gradual
aggredation of the substrate surface may ultimately eliminate surface hydrology features
relevant to aquatic species. Phragmites stands have demonstrated significantly greater
rates of internal nitrogen cycling (both immobilization and mineralization) as compared to
stands of native Spartina patens (Windham and Ehrenfeld 2003). Phragmites sequestered
more nitrogen in live biomass and detritus compared to Spartina patens, but simultaneously
stimulated microbial nitrogen mineralization at an equivalent rate, potentially affecting
total nitrogen pools within the wetland along with pathways of nitrogen export. Similarly,
Findlay et aL (2003) demonstrated that the ability of wetlands �o serve as a nitrogen sink
was reduced when former Phragmites stands were restored to a more diverse plant
community.
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TREATMENT OPTIONS
Throughout the United States and Europe, a full suite and combination of physical and
chemical techniques have been tested experimentally in laboratory and field conditions to
gain insight into the control and eradication of exotic P. australis. Experimental control
efforts have varying degrees of success, and no singular effective technique has been
identified as the best approach to managing P. australis infestations. Physical controls
tested include manual and mechanical means of inducing stress (e.g., shading, drowning,
mowing, burning), alteration of site hydrology (e.g., �lling ditches, creating ditches,
creating ponds), and excavation of root systems.
Minchinton and Bertness (2003) demonstrated that alteration of vegetation adjacent to
P. austYalis plots and nutrient pulses each resulted in increased density, height, and
biomass of P. australis shoots. The combination of these treatments also resulted in an
increase in the distance that shoots expanded and their reproductive output. Thus, limiting
disturbance of native vegetation and reducing nutrient loading are critical to preventing the
spread of existing P. australis infestations.
Chemical controls include herbicide application, typically in combination with some form
of physical control for well-established infestations in large areas. Chemical control of
P. australis has been achieved most frequently with a foliar application of imazapyr or
glyphosate, a non-selective herbicide, applied in July to mid-September. (Mozdzer et al,
2008) Herbicide application followed by burning has shown to be relatively effective and
may stimulate the native plant community recovery (Boone et al, 1987)
The NPS has completed an Environmental Assessment for the Outer Banks Group Fire
Management Plan (2001) and a Finding of No Significant Impact (FONSI) was received
(2002) to allow the Seashore to use prescribed burning to manage hazardous fuel loads.
The Seashore conducted a prescribed burn in early 2012.
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PROPOSED MITIGATION
The NCDOT proposes to restore of approximately 50 acres of phragmites dominated
wetland within the Bodie Island Lighthouse Pond SNHA by rehabilitation to its former
function as a brackish marsh. NCDOT proposes a 5:1 ratio for this onsite wetland
restoration to offset wetland impacts associated with Phase I of B-2500. Remaining assets
on the site must have regulatory agency approval prior to use as mitigation on other
projects.
WORK PLAN
Goal 1: Inventory
The NPS identified that control of exotic plant infestation in the Bodie Island SNHAs is the
highest priority site for the proposed mitigation for wetland impacts resulting from the
bridge replacement project.. In 2008, the NPS preliminarily estimated and mapped
approximately 35 acres infested by the exotic P. australis within this SNHA. In 2011,
NCDOT mapped 51.73 acres based on field surveys and photogrammetric analysis as
shown in Figure 1 below.
Prior to site treatment, fixed photo points and vegetation survey plots and will be
established within the marsh area. Photo points will be established near the edges of
phragmites stands. Fourteen (14) 1 square-meter plots will be randomly located within the
surveyed phragmites stands outlined in yellow on Figure 1 below. Additional plots will be
located outside the phragmites stands as control plots. Vegetation plots will be inventoried
for % aerial coverage of phragmites within each plot. Native vegetation will also be
recorded.
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Figure 1
Goa12: Treatment
The use of herbicide treatment(s) (initial and spot treatments) is recommended as the
primary control method and the first step toward effective control. After the initial
herbicide treatment, one or more follow-up methods at each site will be required.
NCDOT and NPS treatment plan follows procedures established in A Guide to the Control and
Manageinent oflnvasive Phragmites,2nd Edition published by the Michigan Department of
Natural Resources in cooperation with several other state and federal agencies. The
guide presents a compilation of techniques, based on four years of research and more than ten
years of land managers' on-the-ground experience, to control the nonnative variety of
phragmites.
NCDOT will follow the Guide's specific recommendations of Approach 2 management strategy
for large, dense stands of phragmites on a wet site:
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1. Treat phragmites stands with Imazapyr and Glyphosate herbicides in mid-summer or
late summer. Wait at least two weeks to allow plant exposure.
2. If prescribed burning is recommended, conduct in the year following herbicide
treatment either in winter (January until prior to spring green-up) or during the
summer.
3. Check site the following growing season for phragmites regrowth and spot-treat
with herbicide if needed.
ADAPTIVE MANAGEMENT
Controlling Phragmites infestations has proven to be a challenging and unpredictable
undertaking for resource managers and landowners across the country. Therefare, adaptive
management is crucial for this wetland restoration project to be successful. Adaptive
management is a process that allows for decision making in spite of uncertainty, with an aim to
reduce uncertainty over time via system monitoring. Our goal is that NCDOT and NPS
Resource Management (RM) staff at CAHA keeps open communication throughout the duration
of the mitigation project in order to achieve success. The following outline is proposed for the
duration of the monitoring period to allow for annual adjustment in the treatment plan based on
success criteria.
• January-March, annually
o Prepare and submit NPS Pesticide Use Proposal (PUP) must be submitted by
NPS on annual basis, requesting authorization to apply speciiic herbicide.
o NPS will notify NCDOT of authorization to apply herbicides via PUP
approval from the NPS Southeast Regional Office.
o NPS authorizes herbicides on individual basis; therefore, there shall be no
substitution of herbicide without written authorization via PUP approval.
o Submit copy of current NC Certified Applicator License(s) must be
submitted to NPS annually and prior to application of herbicide
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• March-June, annually
o Identify areas aerial treatment proposed to occur
■ Initial aerial treatment area includes the entire band of marsh around
the Lighthouse pond (except where spot treatment preferred)
■ Subsequent aerial treatment areas will be determined by annual
evaluation
o Identify areas spot treatment proposed to occur
■ Initial spot treatment areas include areas in close proximity of listed
species as identified by field surveys and areas in close proximity to
visitor use as identi�ed by NPS
■ Subsequent spot treatment areas will be determined by annual
evaluation
o Evaluate recover of target species
■ Identify areas not on target to meet success criteria for recover of
target species (bare areas)
■ Determine if supplemental planting is appropriate
• Mid Summer through mid-November, annually
o Conduct aerial or spot application of aquatic herbicide in identified areas
o Herbicide must be stored, handled, applied, and disposed of by a NC
Certified Applicator in accordance with the label and MSDS
o NC Certified Applicator must be on-site when herbicides are being applied
o NC Certified Applicator is accountable for any and all individuals working
under Applicator's License
o Daily Pesticide Use Log must be maintained by applicator
• By December 31, annually
o Pesticide Use Log must be submitted to NPS
o Monitoring report must be submitted to NPS and agencies
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AVOIDANCE MEASURES
In order to minimize adverse impacts to the resources at Bodie Island Lighthouse Pond,
several mitigation measures must be put in place for proposed activities. These include,
but are not limited to:
• Avoid impacts of herbicides to rare plants:
o Physical cover for individual stems
o Establish buffer zones around sizeable populations of rare plants
o Minimize drift by applying herbicides with proper technique and under proper
conditions through contract specifications. Table 1 below relates droplet size and
expected drift.
Accuflow nozzles allow the user to customize the orifice size to accommodate different
spray jobs. Each nozzle has an array of 32 needle outlets in a circular configuration. The
system operates with 20 psi boom pressure and under 5 psi nozzle pressure. This
boom/nozzle combination produces droplet sizes of 1000 - 1500 microns, depending on
which orifice used.
Table 1: Influence of droplet size on distance of drift. (Klingman, Potts, Akesson, Yates)
Droplet diameter Type of Droplet Time Required Lateral distance
(microns) to fall 10 feet droplets travel
in a 3 mph wind
5
20
100
240
400
1,000
Fog
Very fine spray
Fine spray
Medium spray
Coarse spray
Fine rain
66 minutes
4.2 minutes
lOseconds
6 seconds
2 seconds
1 second
18
3 miles
1,100 feet
44 feet
28 feet
8.5 feet
4.7 feet

• Avoid impacts to wetland soils/hydrology:
o Use aerial application for initial treatments
o Convert to backpack application after control established
• Avoid impacts to water quality:
o Use herbicides that are safe for application in standing water
o Prevent spills of contaminants from entering water bodies or wetlands
• Avoid impacts to visitor experience:
o Perform herbicide application and prescribed burns when visitor use in the area is
as minimal as possible (CAHA staff will provide preferred timeline)
o Inform public of activities through posting signs, press releases, etc.
• Actions must be consistent with NC Coastal Area Management Act
• Prescribed burn actions must be consistent with Minimum Impact Suppression
Tactics (MIST) practices and follow an approved burn plan
Goa13: Monitoring
Monitoring the results of Phragmites control treatments provides critical information that
will allow NPS and NCDOT to assess the efficacy of their actions at the site. NCDOT will be
responsible for all monitoring activities, including coordination with NPS and NHP.
• Fixed photo points will be established across the site at edges or boundaries of
phragmites stands.
• Fourteen (14) 1 square-meter plots will be randomly located within the surveyed
phragmites stands as shown on Figure 1. This density is less than recommended in
the NMFS guidelines but data will be supplemented by aerial photo interpretation.
Three (3) additional plots will be located outside the phragmites stands as control
plots.
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• The vegetation component of the wetland site will be deemed successful if the following
criteria are met:
o After the first year treatment, the total aerial coverage of dense phragmites stands
decreases from the current 50 acres mapped as shown on Figure 1. This will be
reported in the Spring of the following year.
o This trend of decreased aerial coverage of mapped phragmites will continue each
treatment year.
o At the end of the final monitoring year, the total aerial coverage of dense
phragmites stands will be 10 acres or less with stems less than three feet tall.
• Annual reports will be prepared and distributed at the end of each treatment year.
• Subsequent year treatment areas and type of treatment (aerial or spot herbicide,
prescribed burn) will be mapped and reported in the Spring of each year.
Goa14: Educate, Outreach, and Research
The project will provide an educational opportunity for NPS by incorporating invasive species
issues into the interpretive programs provided to visitors. According to NPS, the goal of these
programs "is to provide memorable and meaningful learning and recreational experiences, foster
development of a personal stewardship ethic, and broaden public support for preserving park
resources. Such programs will be successful when they forge emotional and intellectual
connections among park resources, visitors, the community, and park management". Visitors
may learn how to identify phragmites, the cause and effects of invasive species in our state's
natural communities and how they can help to prevent the spread of invasive species. NCDOT
will continue to coordinate with NPS to notify all stakeholders and potential visitors when
treatment will take place. Additionally, as large stands of phragmites die-off, it will be important
to provide the visitors an explanation of what may temporarily appear as destructive, is actually
crucial to restoring the natural community. To this end, NCDOT will explore installing
interpretive signage with NPS near the lighthouse illustrating the needs and goals of the
restoration process.
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An adaptive management plan will provide a valuable site specific opportunity for the NCDOT,
NPS and other stakeholders to learn and understand the best methods of treatment and how the
natural community responds. This information will help provide an effective method of
treatment to ensure the long-term success of phragmites control that may also be applied to other
areas of the Seashore and surrounding coastal areas. Specific details regarding methods, rates
and timing of pesticide application, prescribed burns and effectiveness will be recorded and
available to the public and stakeholders.
SITE PROTECTION AND MAINTENANCE
The site is located completely on National Park Service land and is afforded long-term protection
under federal laws and maintained under NPS regulations.
FINANCIAL ASSURANCES
NCDOT is held by permit conditions associated with B-2500 to complete the mitigation
and monitoring plan for this site. NCDOT has established funds for each project and
within each Division to monitor the mitigation site.
PROJECT COMMITMENTS
NCDOT will work with NPS to solicit grant funding for long term management of the site
by NPS. NCDOT has coordinated with the Division and utility personnel to minimize
encroachment of phragmites from outside the site along the eastern boundary. Dominion
Power and NCDOT Division Roadside Environmental Unit have agreed to discontinue
mowing of phragmites stands within the utility easement and along the roadway adjacent to
the Bodie Island Lighthouse pond. Vegetation management in these areas will be achieved
through herbicide treatment.
21

REFERENCES
Able, K.W. and Hagan, S.M. 2000. Effects of common reed (Phragmites australis) invasion on
marsh surface macrofauna: response of fishes and decapod crustaceans. Estuaries 23(5): 633-
.�.
Batterson, T.R. and Hall, D.W. 1984. Common reed — Phragmites australis (Cav.) Trin. ex
Steudel. Aquatics 6(2): 16-17, 20.
Benoit, L.K. and Askins, R.A. 1999. Impact of the spread of Phragmites on the distribution of
birds in Connecticut tidal marshes. Wetlands 19(1): 194-208.
Bertness, M.D., P.J. Ewanchuk, and B.R. Silliman. 2002. Anthropogenic modification of New
England salt marsh landscapes. Proceedings of the National Academy of Science 99: 1395-1398.
Bontje, M.P. 1987. The application of science and engineering to restore a salt marsh. pp. 16-
23 In Proceedings of the 15th Annual Conference on Wetlands Restoration and Creation.
Hillsborough Community College, Tampa, FL, USA.
Boone, J.L., C.E. Furbish, and K. Turner. 1987. Control of Phragmites communis. Results of
burning, cutting, and covering with plastic in a North Carolina salt marsh. Institute of Ecology,
University of Georgia, CPSU Technical Report No. 42.
Chambers, R.M., L.A. Meyerson, and K. Saltonstall. 1999. Expansion of Phragmites australis
into tidal wetlands of North America. Aquatic Botany 64: 261-273.
Fell, P. Weissbach, S.P., Jones, D.A., Fallon, M.A., Zeppieri, J.A., Faison, E.K., Lennon, K.A.,
Newberry, K.J., Reddington, L.K. 1998. Does invasion of oligohaline tidal marshes by reed
grass, Phragmites australis (Cav.) Trin. ex Steud., affect the availability of prey sources for the
mummichog, Fundulus heteroclitus L. Journal of Experimental Marine Biology and Ecology
222: 59-77.
22

Findlay, S., Groffman, P., Dye, S. 2003. Effects of Phragmites australis removal on marsh
nutrient cycling. Wetlands Ecology and Management 11(3): 157-165.
Hanson, S.R., Osgood, D.T., Yozzo, D.J. 2002. Nekton use of a Phragmites australis marsh on
the Hudson River, New York. Wetlands 22(2): 326-337.
Hara, T., van der Toorn, J., Mook, J.H. 1993. Growth dynamics and size structure of shoots of
Phragmites australis, clonal plant. Journal of Ecology 81: 47-60.
Leonard, L.A., Wren, P.A., Beavers, R.L. 2002. Flow dynamics and sedimentation in Spartina
alterniflora and Phragmites australis marshes of the Chesapeake Bay. Wetlands 22: 415-424.
Meyerson, L.A., K. Saltonstall, L. Windham, E. Kiviat, and S. Findlay. 2000. A comparison of
Phragmites australis in freshwater and brackish environments in North America. Wetlands
Ecology and Management 8: 89-103.
Minchinton, T. E. and M. D. Bertness. 2003. Disturbance-Mediated Competition and the Spread
of Phragmites australis in a Coastal Marsh. Ecological Applications 13(5): 1400-1416.
Mozdzer, T.J., C. J. Hutto, P.A. Clarke, and D. P. 2008. Field Efficacy of Imazapyr and
Glyphosate in the Control of Non-Native Phragmites australis. Restoration Ecology, 16(2):
221-224.
National Invasive Species Council. 2008. 2008-2012 National Invasive Species Management
Plan. 35 pp.
National Park Service. 2002. Director's Order #77-1: Wetland Protection. Available on the
internet at: http://www.nps.�ov/policy/DOrders/D077-1-Reissue.htm
23

National Park Service. 2012. National Park Service Procedural Manual #77-L• Wetland
Protection. Available on the internet at:
http: //www.nature.nps. gov/water/wetlands/assets/docs/DO_77-
1 PROC_MANUAL 2012_Revision FINAL.pdf
Paxton, B. 2007. Potential impact of common reed expansion on threatened high-marsh bird
communities on the seaside: breeding bird surveys of selected high-marsh patches. Center for
Conservation Biology Technical Report Series, CCBTR-07-03. College of William and Mary,
Williamsburg, VA. 19 pp.
Posey, M.H., Alphin, T.D., Meyer, D.L., and Johnson, J.M. 2003. Benthic communities of
common reed Phragmites australis and marsh cordgrass Spartina alterniflora marshes in
Chesapeake Bay. Marine Ecology Progress Series 261: 51-61.
Rooth, J.E., Stevenson, J.C. 2000. Sediment deposition patters in Phragmites australis
communities: implications for coastal areas threatened by rising sea level. Wetlands Ecol. and
Manag. 8: 173-183.
Rudrappa, T., Bonsall, J., Gallagher, J., Seliskar, D., Bais, H. 2007. Root-secreted
allelochemical in the noxious weed Phragmites australis deploys a reactive oxygen species
response and microtubule assembly disruption to execute rhizotoxicity. Journal of Chemical
Ecology 33: 1898-1919.
Talley, T.S., Levin, L.A. 2001. Modification of sediments and macrofauna by an invasive
marsh plant. Biol. Invasions 3: 51-68.
U.S. Army Corps of Engineers. 2005. Environmental Assessment for Control of Phragmites
australis in South Carolina. 49 pp.
Virginia Department of Conservation and Recreation. 2009. Management Plan for Phragmites
australis on the Seaside of Virginia's Eastern Shore. Nat. Heritage Tech. Rep. 09-04. 81 pp.
24

Windham, L. and Ehrenfeld, J.G. 2003. Net impact of a plant invasion on nitrogen-cycling
processes within a brackish tidal marsh. Ecological Applications 13(4): 883-896.
Windham, L. 2001. Comparison of biomass production and decomposition between Phragmites
australis (common reed) and Spartina patens (salt hay grass) in brackish tidal marshes of New
Jersey, USA. Wetlands 21: 179-188.
Windham, L. and Lathrop, R. 1999. Effects of Phragfnites australis (common reed) invasion on
above-ground biomass and soil properties in brackish tidal marsh of the Mullica River, New
Jersey. Estuaries 22: 927-935.
US Army Corps of Engineers and US Environmental Protection Agency. 2003. Memorandum
to the Field: Model Compensatory Mitigation Plan Checklist for Aquatic Resource Impacts
Under the Corps Regulatory Program Pursuant to Section 404 of the Clean Water Act and
Section 10 of the Rivers and Harbors Act. Dated November 7, 2003. Available on the internet
at http://www.mitigationactionplan.gov/checklist.pdf
25

Appendix A: Material Safety Data Sheets
Habitat — Imazapyr
Rodeo — Glyphosate
26

� w.. � ����
ihe Chem3cal Camp�ny
Safety Data S heet
HABITAT HERBICIDE
Re�isinn date : 2U1?_I[}31�8 Page: 119
Version: 1.5 (302358351SD5 CPA U5lE�
1. Product and Company Identification
Camnanv
BASF C�RP�RATlON
'} 00 Park Avenue
Flarham Park, NJ [}7932, USA
Substan�a number:
Moleeufar formula:
Chemical family:
. Synonyms:
2. Hazarcfs Identificativn
Emerpsncv a�erview
24 Haur Emer4enc}r F3esponse Information
C H �MTR EC: 1-800-424-9304
BASF H{7TLIME: 1-800-832-HELP (435Tj
O�C10U063383
C(13} H(15} N(3] O{3). C[3} H{9j N
imidazvle deri�ati►►e
Isoprapylamine sal# af imazapyr
CAllTION:
KEEP �UT OF R�ACH OF CHlLUREN.
Avvid contact wikh the s�Cin, eyes and clothing.
Avoid inhalation af mists,hrapours.
See Product Latsel for additional precautivnary statements.
State af matter: loquid
Colour: blua, clear
{3dour: ammonia-IiEce, faint odour
Potentlal healt8 effe�ts
Primary routes nf expnsure:
Routes af entry for solids and liquids include eye and skin contact, ingestion and inhaiation. Ftoutes of entry for
gases include inhalatinn and eye oontact. 5kin cvntact may be a route of sntry far liquified gases.
Acute toxicity:
Relativeiy nantoxic aRer singls inges6an. Slightly taxic after shorF-term skin c.�ntact. Relatively nantoxic after
short-term inhalation.
Irritation 1 corrosian:
May cause slight but temporary ircitatinn ta the eyes. May cause slight irritation tv the skin.
Sensitization:
Skin sensit¢ing effe�ts were not abserved in animal studies.
Poiential �nalronmerrtal effects

5afety Data Shee�
HABITAT HERBICIDE
Re�isinn date : 2q121Q3108 i'age: 219
Versian: 1.5 3�235835ISDS CPA U51EN
Aquatio toxicity:
There is a higF� probability khat #he praduct is not acutely harmful to fish.'There is a high prahability that tfi�e
product is not acuteiy harmful to aquatic invertebrates. Acutely harmful for aquatic plants.
Terrestr€ai toxicity:
With h�gh prohahiiity� not acutely harmful to terrestrial organisms.
3. Composition 1 lnformation on Ingredients
CAS Number Content IWMf1 Chemical name
8i5'f 0-83-0 �= 27.77 - a= 27.8 46 Isapropylamine salt of imazapyr
72.2 % Praprietary ingredients
4. Firs#-A9d Measures
General advice�
First aid prorriders should wear {�ersnnal protective equipment ta preveni exposure. Remave ovntaminated
clothing. Mo�e persvn to fresh air. If person is not breathing, caA 911 or ambulance, then giva artiflcial
respiration, preferably mouth-to-mauth if passible. Call a poisan cantrol oenter or physician fcrr treaMent advice.
Fiave the praduct container ar label with you when ealling a paison control canter or doctor or going for
treatment.
If inha�ed:
Remove ths affected individual intv fresh air and keep the person calm. A�sist in breathing if necessary.
if on skin:
Rinse skin immediately wi�h pleniy of wafer fvr 15 - 2D minutes.
If in eyes:
Hold eyes vpan and rinse slawly and gently with wat�sr far 15 to 20 minutes. Remove contact lenses, if qresent,
after first 5 minutes, then continue rinsing.
If swallowesi.
Fiave persan sip a glass vf water if ab�e to swallaw. Dv not induce vamiting unless told b by a paison cvntrol �
center ar dvctor. Ne�er induce vvmrting ar give anything by mouth if ihe vidim is uncanscious or hsving
eonvulsions.
Nate_!o ph,y,sician
Traatment: Treat accflrding to symptvms {decaMamination, vit�l functians}, no lcnown
speciic antidote.
5. Fire-Fighting Measures
Flash point:
5elf-ign�ian temperature:
Suitable extinguishin� media:
foam, dry pawder, car�on cf6oxide, water spray
Nan-#larnmable.
nvt selF-igni�ing
Hazards during fire-fighting:
carban monoxide, eart}on dioxide, nitrogen oxide, nitrogen dioxide, Hydrocarbons,
If product is heated above decompasition temperature, toxio uapours will be released. The substanceslgroups of
substanoes meritioned can be releas+ed if the praduct is involved in a fire.
Protective equipment for fire-flghting:
Firefighters should be equipped with self-contained breathing apparatus and turn-ouk gear.

Safety Data Sheet
HABITAT HERBICIDE
Re�ision date : 2a121�31Q8 Page: 319
Version:9.5 3D2358351SDS CPA USIEN
Further ir�formatfon:
Evaauate area of all unneeessary personnel. Contain cvntaminated waterKrefighting water. da not allow #v
enter drains or waterways.
�i. Accidental release measures
Personal precautions:
Take appropriate protective measures. Clear area, Sh�t off source of leak anly under safe c�onditivns.
Exkinguish saurces af ignibian nearby and downwind. �nsure adequate venti�atian. Wear suitable personal
prvtective clothing and equipmenf.
Environmental precautions:
Dn not discharge into fhe subsaillsoil. Do not discharge into drainsisurfaoe waterslgroundwater. Contain
cnntarninated water�refighting water.
Cleanup:
❑ike spillage. Pick up with suitable absarbent materiai. Place into suikahle conkainers for reuse or disposal in a
licens+ed facility. Spifled substanoelproduct shouki be recavered and applied according to label rates whenaver
possible. If application of spilied subsfancelproduct is not passibfe, ttien spills should be contained, sofidified,
snd placed in suitable containers for disposal. After decvntamination, spill area can he washed with water.
Coflect wash water for appraved dispasal.
7. Handling and Storage
Handlina
General ad�ice:
FtECaMMENDATIOIdS ARE FQR MANUFACTURINC,, COMMERCIAL BLENDIN�G, AN[] PACKAGlNG
WQRK�RS. PESTICIDE APPLICATtIRS & WORKERS must refer to the Product Label and airecrions for Use
attached to the product for AgricuiEural Use Requirements in accordanoe with the EPA Worker Protection
Standard 40 CFR part 17D. Ensure adequate ventilation. Pro�ide good ventilation of wvrking area.{laeal exhaust
ventilafion if necessary). Keep away fram saurcas of ignition - Na smoking. Keep csontainer tighify sealed.
Protect cnntents fram the effects of light Proted against heat. Protect fram air. Handle and open container with
care. Do nvt open until ready to use. Qnee cantainer is vpened, conient should be used as sovn as possiple.
Avoid aerosol formation. Ar�oid dust farmativn. Provide means fnr contralling leaks and spills. Do not r�turn
residues to the starage containers. Foflaw labei warnings eVen aRer cantainer is empt`ted. The substanc�f
produci may 6e handled only hy apprapriateiy trained personnel. Avoid aA direct contact with the
substancelpraduct. Avaid oontact with the skin, eyes and clothing. Avvid inhala�ion of dustslmistsivapours.
Wear suiEable persortal protscfive clothing and equipment.
Protectfan agalnst fire and exploslon:
The relevant fire protectian measures should tre noted. Fire exEinguishers should be kept handy. Avoid alf
sources of ignition: heat, sparks, ap�n flame. Sources of ignition shvuld be kept well c�ear. Avaid axEreme heat.
Keep away frvm oxidizable su6stances. Electrical equipment should ovnfvrm to national elec#ric cnde. Ground
all transfer equipment pro�erly to prevent electrostatic discharge. Efectrostatic discharge may cause ignition.
Sto" ras�e
General advice:
I(eep anly in the originai container in a eool, dry, well-ventflated place away from ignitian sources, heaf or flame.
Protect cAntainers from physical damage. F'rotec# againsk contamination. ihe autharity permits and stvrage
regulations must be vbserved.
Storage incompatibility:
Generaf advioe: Segregate from incampa6ble substances. Segregafe ham foods a�d animal feeds. Segregate
fram textifes and similar materials.
Temperature tolerance
Prated from temperatures helow: �°C
Changes in the properties of the product may occur if suhstanoelprc�duct is stared below indicated temperature
for extended periads vf time.

Safety Data Sheet
HABITAT HERBICIDE
Revisiar� date : 20`i2/031U8 page: �F19
Version:9.5 302358351SDS CPA �1SIEN
Pratect from temperatures abave: 40 °C
Changes in khe properties of the product may occur if substancelprvduct is stored above indicated kemperature
for extended periods of time.
8. Ex�osure Cnntrvfs and Personal Protection
Users of a pesticidal product shfluld reter to the product la6el for personal pratecti�e equipment
requirements.
Advice on sysfem design:
Whene�er possible, engineering controls should be use� to re►inimize the need for personal protecti�e
eQuipment.
Personal nratectir►e epufp�ent
RECC]MM�NDATIOHS F4R MANUFACTURING, COMM�RCIAL BLENDIHG, ANQ PACKAGING
YVpRKERS:
Respiratvry protectian:
Wear res�siratnry protection if ventilatian is inadet�uate. Wear a NIOSH-oertified (or equivalenty TC23C
ChemicallMechanical type filter system to remove a cvmbination af partic�es, gas and vapours. Far situatians
where the airbarne ann�entrations may exoead the level for which an air purifying respiratvr is effectiva, or
where the levels are unknvwn or Immediately �angerous to Life or FEeafth {IDLH), use Nt�SH-oertified full
facepiece pressure demand sel#-contained breathing apparatus {SCBA? ar a full facepiece pressure demand
supplied-air respirator {SAR} with esca;re provisinns.
Hand proteetion: .
Chemical resistant protective gloues, Pratective glove selection must ba based on the use�'s asse&sment vf t#ra
workplaoe hazards.
Eye protection:
Safety glasses with side-shields. Tightly fitting safety gaggles (chemical goggiesy. Wear face shield if splashing
hazard exists.
Body protection:
Bady protection must be chasen depending on activity and possible exposure, e.g. head protection, apron,
proteotive boots, chemical-pratectian suit
General safety and hygiene measures:
Wear long sleeved work shirt and k��g work parits in addition to other stated persvnai protective equipment.
Work place should be equipped wit� a shower and an eye wash. Handle in accordance with good industrial
hygier�e and safety practice. Personal pratective ec;uipmenE should �e decontaminated prior to reuse. Gloves
must be inspected regularly and prior to each uae. Replace if necessary {e.g. pinhale IeaksJ. Take off
immediately all contaminated clothing. Stnre work clothing separately. Hands antllor faae should 6e washed
hefore hreaks and at the end of the shift. No eating, drinking, smaking or tobacxa use at the place t�f work. Keep
away from fovd, drink and animai feetfing stuffs.
9. Physical and Chemical Properties
Form:
Odaur:
Colour:
pH value:
Freezing point:
Boiling point:
Vapourpressure:
liq�id
ammonfa-like, faint rsdour
blue, elear
fi.6 - 7.2
approx. D°C ( 9,0�3.3 hPa) fnformatian applies td the
solvent.
apprax. 1UD °C { 1,013.3 hPa] lnformatian applies to the
salvent.
apArox. 23.3 hPa
� 100 hPa
( 20'C) Inforrr�atian apAlies to ti�e
soluent.
( 50 °C) Informafron applies to the
svNent.

Safety Data Sheet
HABiTAT HERBICIDE
Revisis�n date : 2�92103108 page: 51g
Versian: 1.5 30235835lSaS CPA US1EN
Density:
Vapvurdensity:
V'�scasity, dynamic:
5olubility in waEer:
Malar mass:
1 Q. S#ability and Reacti�ity
1.04 - i.09 glml
1.�955 glc�n3
1.4755 glan3
approx. � 1 mPa.s
32fl.4 glmvl
t � � °C)
{ 50 °Cj
nat determined
{ 20 °C)
misc:ihle
Canditions ta avoid:
Avaid aU sources of ignition: heat, sparks, open ftame. Avvid pralanged stvrage. Avoici electro-static discharge.
Avaid contaminaEian. Avo�d praEnnged exposure tci extreme heai. Avoid extreme temperatures.
Suhstances to a�oid:
oxidizing agents, redurang agents
Hazardous reactions:
The product is chemically stable.
Decomposition products:
Hazardous decompvsRian praduets: No haxardaus decompvsitian produets if stfl�ed and handEed as
prescribedlir�dicated., Prolooged ihermal laading can resuft in prodacts of degradation befng given off.
Thermal decomposition:
Pvssible thermal deoomposition products:
carbon monaxide, carban diaxide, n�rogen axide
Stable at ambient temperature. If product is he�ted abo�e decompositian temperature taxic vap4urs may be
released. If praduct is heated a�ave decomposikior� temperature hazardaus fumes may be released.
Corrosion tv metals:
Corras�ve effect on: miid stael brass
Oxidizing properdes:
not fire-propagat�ng
PEat an oxidizer.
7 7. Taxicalogical information
Acuts toxicity
Oral:
Ty{�e of �alus: LD5Q
Species: rat {malelfernale�
Value: � 5,000 mglicg
Inhalation:
Type of value: LC5D
5pecies: rat (malelfemaleJ
Value: � 5.3 mgll {L�ECD Guideline 4�3j
Exposure time: 4 h
An aerosol w�s tested.
aermal:
"�ype of value: LD54
Species: rabbit {maleffemale)
Value: � 2,Q00 mglkg
Irritaiion 1 carrosion

Safefiy Data 5heet
HABITAT HEF�BIGlDE
Re�ision date : 20121{]3108 Page; 619
Version: 9.5 {342358351SDS CPA !iSl�N]
Skin;
Species: rabbi#
Result: mildly irritating
Pulethad: Primary skin irritation test
Eye:
Species: rabbit
ResuEt: nvn-irritant
SBnsitixatian:
Skin sensitization test
Species: guinea pig
Result: 5kin sensit¢ing effects were not abser+red in anima! studies.
Genetic taxicity
lnfvrmatron on: emezePYr
Na rrrutagenic e19`ecf was for�nd in varrous tesis with mr�ronrge►arsms end rrrammals.
Carcinogenicity
Iniormation arr: imazapyr
In fong-term s[udies in rats and mica 1n whieh the subs#ance was given by �eed, a csrcr'nogenic effect was nai
obse�veci.
Reproducti�e Eoxicity
lnformatrarr on: imaxapyr
The rssults of animaf studres gava nn Indrer�fian ef a ferti�i[y im,pairing eifecf.
f]e►relopmant:
In,formatiun an: imazapyr
IVo irulrcations af a developmeniaf tdxic /#erataganic eifeet we+� seen in anirr�a! sfudies.
12. Ecological inf�rmation
Fish
lnformstinn on: imerapyr
AeUte:
Dncaorhynchus mykrss/LCSf? (96 h): > 100 mgll
Aquatic in►rertebrates
lnfonmafrv� nn: imaraPY�
Rcufs:
Daphnia magna/EC50 {48 h): � 1L10 m�f
Aquatic plants
7axicity to aquatic plants:
ather swollen duckweedlEC50 {14 d}: p.p22� mgll
ihe product has nnt heen tested. The statement has besn derived from products af a similar structure or
aompasition.

Safety Da�a S heet
HABETAT HERBICIDE
Re�isivn date : 20i2lQ3108 Page: 719
Version: 1.5 3{1235835lSDS CPA USfEN
Mon-Mammals
lnformetron on: imazspyr
{?thar terrestrfal non-rnamm�fs:
maAarr! d►�k/LC50: a 5,OAQ ppm
WJth hrgh pm+hahidity nnt acutely hsrmful to #err+�sfria! arganisms.
Hanay bee2D5�: ? T Di? ug/bee
Wiih high prnbability not �eutely h�mrful to ferrestrral orgarrisms.
aegradahility ! Parsistence
Bialogicai ! Abioiogieal Degredation
�valuafion: Not readily biodegrac4able (by OECD criteriaj.
�ther adverse effects:
The eoalogical data given are those of the actiue ingredient. Da not release untreated into r�atural wafers.
13. Disposat considerations
Waste dispasal of substance:
Pesticide wastes are regulated. Impro�aer disposal af excess pesticide, spray mix ar rinsate is a viofation of
federal law. If pesEicide wastes cannot be disposed o# acc:arding ta label instructians, oontact the State I'esticide
or Enviranmental Cantr4f Agency or the Waxardous Wasfe represenWtive at the near�st EPA Regional CNfice for
guidance.
Cvntainer dispvsal:
Rins� theraughly at least three 6mes {triple rinsey in acoordance with EPA recommendatians. Consult state or
facal disposal authorities far approved alternati�e procedures such as container reeyding. Recommend
crushing, punr.turing or vther rneans to prevent unauthorixed use of used containers.
RCFtr1:
This product is nat regulated by RCRA.
14. Transport Infarmativn
Land transport
L150QT
Sea transport
IMDG
Hazard Gass:
Packing group:
10 number:
Hazard label:
Marine poilutant:
Proper shipping name:
Air transpart
IATAIICA�
Hazard class:
Not c(assiffed as a dangerous good undertranspart regulations
II!
L1N 3082
9, EHSM
Y�S
EMVfR()IVMEiVTALLY HAZAFtl7(7US SUBSTANCE, LIQUiD, h1.O.S.
(contains IMA7APYR 23°�bj

Safety Data Sheet
HABITAT HERB�CIDE
Re�ision date : 2�121031fl8 page: 819
Version:1.5 34235835lSDS CPA EJSIEhf
Padcing group:
I� number:
Hazard la6el:
Proper shipping name:
15. Regulatary lnformation
Federal Re�ulaEions
UAf 3082
9, EHSM
ENVlROt�MENTALLY IiAZARDOUS 5i1B5'i'ANCE, LIQIiID, N.�.S.
(co�tains IMAZAPYR 23%j
Re�istrativn status:
Crvp Protectfon TSCA, U8 released 1 exempt
Chemi�ai TSCA, U5 blocked J not listed
05HA hazard eategory: Chranic target organ effects reported; ACGIH TLV established
EPCRA 3171312 [Hazard categoriesj:
Stat r�auFati ,r�ns
CA Prop. 65:
There are no listed cFiemicals in this product
76, �ther Informatian
Acute; Chronic
Ra#er ta product label for EPA registration numk�er.
Reaommended use: herhici�e
iVfPA Hazard codes:
Health : 1 Fire: 1 Rea�ti�rity: 1 5peeial:
We suppart uvorldwide Responsibie Care� initiatives. We value #he heaEth and safety vf our employees,
customers, suppliers and neighbors, and the protection of the environmerit. flur commitrnent to Responsible
Care is Integral to oonducting our business and apera#ing our facilities in a safe and environmentally responsihle
fashion, supporting aur customers and suppliers in ensuring the safe and enviranrr�entally sound handlireg af our
praducts, and minimiaing the impact af our operations on saciety and the environment during produ�tian,
storage, franspvrt, use and disposal of aur products_
MSDS Prepared by:
BASF idA Praduct Regufations
msds@basf.00m
MSQS Prepared on: 2�12103108
IMPQR'1'ANT: WHILE THE flESCRIPTlQNS, DES�GNS, DA'FAAND II�F�RMATf�lV CONTAINED HEREIPJ
ARE PRESEIVTED 1N GD�D FAITH ANU BE�IEIIED T(] BE ACCURAiE , tT IS PRQVIQ�D FOR YOUl�
GUIE3ANCE DNLY. 6ECALlSE MANY FACTpRS NWY AFFECT PRC]CESSING OR APP�lCA"C�C3NIL15E, WE
RECDMMEND 7FfAT YOU MAKE TESTS TO �ETERMINE THE SUITABILfTY QF A ARODUCT FOR Y�UR
PARTfGUU4Ft Pl]RPUSE PRIQR TO USE. NO WARRANTIES aF ANY KIPIp, �fTHER EXPRESSED OR
IMPLIEp, INGLLiUIWG WARRAN71E5 (7F MERCHANTABILITY �R FITNESS FQR A PARTICULAR
PURPOSE, ARE MADE R�GAR�ING PRDDUCTS UESGRlBEC] QR DESIG�FS, DATA OR IAfFflRMATION
S�T F{3RTH, �R 7MAT THE PRODUGTS, DESIGPiS, DATA OR IIdFORMATIQN hAAY BE USE� WITHOUT

Safe#y Data Sheet
HABlTAT HERBlCIDE
Revision date : 2C}1
Version: 1.5
INFRINGING THE lNTELLECTUAL PRaPERiY RIGHTS f3F OiHERS. IN NO CASE SHALL THE
DESCRIPTEONS, IIdFQRf�WTI�N, l7ATA OR DESIGNS PROVID�D BE CON5IDER�D A PART QF DUR
TEF2MS AND CONC1fTIONS aF SALE. �UR'fHER, YOU E]tPRESSLY UNDERSTAND AIVD AGREE THAT
iHE DESCR�PI'IDNS, DESIGNS, C3Ai'A, APJD INFORMATIOM FURIVISHED 8Y OUR COMPAPIY
H�REUNDER ARE GNEhI GRATIS ANO W� ASSUME NG OBLIGATIOIV �R LIABILI�1' FOR THE
I�ESCRIPTIQPI, DESIGIVS, DATA AND Ih�FOFtMATIQN GIV�N OR RESULTS QBTAINED, ALL SUCli BEIIVG
GIVEIV AND ACCEPTED AT YUUR RISK.
EWD OF OATA SfiEET

MATERIAL SAFETY DATA SHEET
Emergency Phone: [phone]
����`, Dow AgroSclences LLC
�M1JV�' AgroSciences Indianapolis, IN 4G268
Effective Date: 3123104
RC3DE0��` HERBICIDE Praiuci Code: 84825
MSDS: 006694
1. PRQDUCT AND COMPA�iY IDEiVTIFICATION: �xTINGUISHING MEDIA: Faam, COZ, Dry Chemical
PR4Dl1CT: Rodeo* Merbicide FIRE ANQ ExP1.�510N HAZAROS: Foam fire
extinguishing sysiem is preferred because uncontro{led
COMpAMY IDENTfFICATIQN: water can spread possible contamination. 7oxic irritating
Dow AgroSciences LLC gases may be formed under fire canditions.
8330 Zions�ille Raad
Indianapolis, IN 48268-1189 FlRE-FIGHTlIVG EqllIPMENT: Use positive-pressure, self-
2. COMP0517'IONIINF�RMATION ON INGREDlENTS: �Qntained breathing apparatus and full pr4tective
equipment.
Glyphosate IPA: CAS # a38641-94-Q 53.8°/a � ACCIDENTAL RELEASE MEASURES:
N-(phosphonD-methyl)
glycine, Isopropylamine pGTION TO TAKE FOR SPILLS: Absorb small spiils with
Salt an inert absorbent material such as Hazorh, Zorball, sand,
Balance, TO�tal 46•�°� or dirt. Report large spills to Dow AgroSciences on 800-
3. HAZARDQUS IDENTIFICATIONS: 9�2-5994•
EMERGENCY �VERVIEIN T. HANDLING AND STORAGE:
Clear, pals yellow liquid, May cause eye irrita#ion. 5fightly PREGAUTIQNS TD B� TAKEN !N HANDLING AND
toxic fo aquatic organisms. STQRAGE: Keep out of reach of children. Do not swaAow.
EMERGEMCY PHDNE NUMBER: $00-992-5994 Avoid contact with eyes, skin, and clothing. Avoid breathing
�apors and spray mist. Handle concentrate in ventilated
4. FIRST AID: area. UVash tharoughly with soap and water after handling
and before eating, chewing gum, �sing tobae�o, using ti�te
�YE: Flush eyes tharoughly wifh water for several minutes. tnilet or smoking. Keep away from food, feedstuffs, and
Remo�e contact lenses after initial 1-2 minutes and water suppfies. Store in originaf containerwifh the lid tightly
eontinue flushing for ser►�ral additional minutes. if efiFects clased. S#ore abo�e 10°F (-12°C} ta keep frorn crystallizing.
occur, consult a physician, preferably an ophthalmolagist. $. �xP�D&URE CON7ROL51PERSONAI. PROT�GTI�N-
SKIN: Wash skin with plenty of water. These precautions are suggested for canditions where the
potential for exposure exisfs. Emergency candifions may
IMGESTI�N: No emergency medical treatmsnf ne�essary. require additionaf precautions.
INFfALATlON: Remo�ve person to fresh air; if effects occur, EXP03URE GIIIDELINES: None established
consul# a physician.
Eh[GINEERING C�NTR�LS: Good generai �entilation
M�TE TO PHYSiC1AN: No specific antidote. Treatment of should be su�eient far most conditions. Local exhaust
exposure should be directed at fhe cantrol of symptoms �enfilatian may be necessary for some operations.
and fhe clinical condition of the patient.
5. FIRE FIGHTING MEASURES: RE�DMMEN�ATIONS FOR MAIdl1FACTURING,
COMMERCIAL BLENDING, AND PACKAGfNG
FI.ASH ROINT: �214°F (�101°C} WDRICERS:
ME7'HOD USED: Setaflash
FLAMMABLE LIMITS:
LFL: hEot applicabfe
UFL: Not applicable
"Tradema�ic of Dow AgraSe�ences LLC
EYElFACE PROTECTION: Use safety glasses.
SKIN PROTECTIQM: No precautions rather than clean
body-cnvering clothing should be needed.

MATERIAL SAFETY DATA SHEET
��,%�Dow AgrvSciences
Emergency Phnne. 804-992-5994
Dow AgroSclences LLC
Indianapolis, IN 46258
Effective Date: 3123104
RQDEfl* HERBICIDE Product Cvde: $4825
MSDS: 44B694
�������. �������. ---
RESPIRAT�RY PRQ7'ECTI�N: Far mast conditions, no
respiratary protection should be needed; howe�er, if
discomfo�t is experienced, use a NIDSH approved air-
purifying respirator.
APPLICATIQNS AND ALL OTHER HANDLERS: Please
refer to the product label far personal pratective clothing
SYSTEMIC {07HER TARGET ORGAM) EFFECTS: Far a
similar materiai, glyphosaie, in animals, effects ha�e been
reported on t�e following organ: liver.
CANCER INFQRMA7"IDN: A similar material, gfyphvsats,
did not cause cancer in laboratory animals.
and equ�pment. iERATULOGY j61RTH OEFECTSj: For glyphosate IPA,
9. PHYSICAL AND CHEMICAL PROPERTIES• �vailable data are inadequate far e�aluation of potential to
- cause birth defects.
APPEARANCE: Clear, pafe yellow liquid
DENSIiY• 10.Q - 1�.5 Ibslgal REPRODUCTiVE EFFECTS: For gEyphasate IPA,
pH; �,g _�,p available data are inadequate to determine effects on
�DOR: None repr4duction.
S�LIIBfLITY IN WATER: Miscible
SPECIFIC GRAVITY• 1.29 gm/L MUTAGEHICITY: For a similar material, glyphosate, in-
FREEZfNG POENT: -7°F --9 Q°F (-21°C --25°Cj vi#ro and animaf genatic ioxicity studies were negati�e.
70. Sl'ABILITY AND REACTIVITY: 72. ECOLQGlCAL INFORMATION:
STABII.ITY; (CONDITIONS TO AV�ID} Stable under ENVIR�NMENTAL �ATA:
normal starage canditions. ECOTOXICQL�GY:
INCOMPAFIBILITY: (SP�CIFIC MA7ERfALS TD AVDID) Material is practically non-toxic to aquatic orgartisms on an
Gaivanized Qr unlined steel (except stainless steel} acute basis (LC� ar ECSn is ?100 mglL in most sensitive
cnntainers or spray tanks may praduce hydrogen gas which species tesied).
may form a highly cambustible gas mixture. Acute LC� for raint�ow trout (Oncorhynchus mvkissf is
}250U mgl�..
HAZARDOUS D�C�NlPOS1TI0{V PRODUCTS: None Acute immobilizafion EC30 in water flea CDaphnia magnal is
known. 918 mglL.
Material is practically non-toxie to birds an an acute basis
HAZARDOUS P�LYMERIZATIDN: Nat knawn to occur. fLD� is �2Q04 mglkg}.
A�ute oral LD� in bobwhite (Colirrusyirqrnianusl is �2000
71. TOXICOL�GICAL INFURMATiON: mg/kg.
i"he L.C� in earthworm Eisenia foetida is �1000 mglkg.
EYE: May cause slight femporary eye irritation. Cornea! Acute cvntact LD� in honey hee (Anis mellrferal is �10a
injury is unlikely. �g��e.
Acute oral LD� in haney bee CA�ais mellrfera� is ?i UQ
SKIN: Essentially non-irritating to skin. Prolonged skin Ng/bee,
contaet is unlikely to result in absorption of harmful Grawth inhibition EC�o in green alga {5e�errastrum
amounts. ihe L.D� for skin absorption in rabbits is �S�OQ capricomufum) is '127 mgll..
mglkg. Did not cause allergic skin reactians when tesfed in Growfh inhibitian ECSa in cluckweed (Lemna s�a_} is 24.4
guinea pigs. mglL.
INGE5TIDM: Very law taxicity if swallowed. Warmful effects 13. DISPOSAL C�NSIDERATIONS:
n�t anticipated from swallowing smal! amounts. The oral DISPOSAL METH�D: If wastes andlor containers cannot
LD� f4r rats is �5Qa0 mglkg. be dispased of ac�ording ta the product label directions,
INHALATiON: Brief expasure (minutes} is naf likely to �fsposal of fhis material must be in accordance with yaur
cause ad�erse sffects. '�he aerasol LC� for rats is �6.37 loca! or area regulatory autharities.
mglL for 4 hours.
`Trademark of Dow AgroScienees LLC
7

NiATERIAL SAFETY DATA SHEET
���UDow AgraSciences
Emergency Phone: 800•
Dow AgroSciences LLC
IndlanapoBs, IN 4fi268
Effective Date; 3123104
R�DEO� HERBIClDE Product Code; 84825
MSDS: 006694
This information presented below only applies to the
material as supplied. The idanti�cation based on
characteristic{s) or listing may not a�ply i# the material has
been used or ofherwise contaminated. It is the responsibility
of the waste generatar to determine the toxicity and
physical properties af the materiaf genera#ed to det�rmine
the proper waste iderrtiflcatian and disposal methods in
compfiance with applicable r�gulations.
STATE RIGHT-T�-KNOW: This praduct is nat knawn to
eontain any substances subject to the discfosure
requ�rem�nts af
PVew Jersey
Pennsylrrania
OSHA HAZARD COMMUNICATION STANDARD: T'his
product is a"Mazar�aus Chemi�al" as defined by the �SHA
If the material as supplied becomes a waste, follvw all Hazard Communicatian Standard, 29 C�R 191 Q.'12Da.
applicable regional, national and Ioca� laws and regulations.
74. TRANSPQRT INF�RMATIDhI: COMPREHEN5IVE ENVIRONNlENTAL RESPaNSE
CQMPENSATfON AND LlABILITY ACT (CERCLA, ar
U.S. DEPARTMENT OF TRANSPQRTATIaN (DOT) SUPERFUNDj: To the best of our knowledge, this product
INFURMA7I�N: contains na chemical.subject to repariing under CERCLA.
For aEl package sizes and mades of transportat�an:
This material is not regulated far transport.
15. R�GULATORY IMFORMATIC3N:
MOTICE: The information herein is presented in good faith
and believed to be a�curate as of the effective date shawn
above. Hawever, na warranty, express or implied, is gi►►en.
Regulatory requirements are subject ta change and may
differ from one lo+cation to another; it is the buyer's
responsibility to ensure that its activities comply urith
federal, stafe or prouincial, and local laws. The fallowing
specifi� information is made far the purpose af complying
wit� numerous federal, state or pravincial, and locaf faws
and regulations.
U.S. REGl1LA,TlONS
SARA 393 INFaRMATIDN: To the best of our knowledge,
this product cantains no chemical subject to SARA Title Ifl
Section 313 supplier notification requirernents.
SARA HAZARD CAiEGORY. 'This product has been
reviewed according to the EPA "Mazard Categories"
promulgated under 5ectior�s 311 and 312 0# the 5uperFund
Ar'nendment ar�d Reauthorizatian Act of 1986 {SAFtA 7itle
Ifl) and is cQnsidersd, under applicable definitions, to meet
the follawing categories:
Not tv have met any hazard ca#egary
NATl�NAL Fff�� PROTECTIDN ASSOCIATION [NFPAj
RATIAIGS:
CATEG�RY RATING
Health 1
Flammability 1
Reactivity p
16. �fHER INF�RMATIDN:
MSaS STATUS: Revised Sectians: 3,4,11,12,13, 9 4& 15
Refere�ce: ❑R-Q369-8028
Replaces MSDS Qated: 1112100
�acument Code: D03-148-UO2
F�eplaces Document Cade: D03-148-001
T�XIC SU6STANC�S CnNTROL ACT (i3CA}: All The Information Herein Is Given In Gand Faith, But No
ingrectients are on the TSCA inventary or are not required 1�►►arranty, Express �r Implied, Is Made. Gonsul# Dow
to be fisted on the TSCA inuentory. AgroSciences For Further Infarmation.
"Trademartc of Dnw AgroSciences �LC
:�